- 47 - APPENDIX B Summary of Conceded, Deemed Conceded, Computational, and Settled Issues The following is a summary of issues and/or adjustments conceded, deemed conceded, of a computational nature, or settled. The Income Tax Cases I. Docket No. 9294-95, Cordes Finance Corp.: A. 1991: 1. Respondent adjusted petitioner’s income for 1991 to reflect additional gross receipts of $355,200. Petitioner concedes this adjustment. 2. Respondent adjusted petitioner’s income for 1991 by $37,505, pursuant to sec. 482, to reflect an improper deduction for interest expense. Petitioner concedes this adjustment. 3. Respondent readjusted petitioner’s reported bad debt deduction for 1991 by $501,267 to reflect actual realized bad debts for the taxable year. Respondent concedes this adjustment. 4. Respondent determined petitioner used an incorrect method of accounting for 1991 and readjusted petitioner’s interest income by $859,338 to reflect interest accrued under the accrual method of accounting. The parties stipulated that the final decision in Cordes Fin. Corp. v. Commissioner, T.C. Memo. 1997-162, affd. without published opinion 162 F.3d 1172 (10th Cir. 1998), would decide the proper amount of petitioner’s interest income for 1991. In accordance with the parties’ stipulations, respondent concedes this adjustment. 5. Petitioner conceded an increase in its interest income in the amount of $16,600. This concession does not appear to relate to any specific adjustment in the notice of deficiency. 6. Petitioner claimed a net operating loss for 1994 and carried a loss back to 1991. Petitioner concedes it was not entitled to claim a net operating loss in 1994 or carry a loss back to 1991. 7. Respondent determined petitioner was liable for a penalty for 1991 pursuant to sec. 6662(a) for substantial understatement of tax. PetitionerPage: Previous 37 38 39 40 41 42 43 44 45 46 47 48 49 50 51 52 53 54 55 56 Next
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